NCS000389_Cover Letter_20190408

RaY COOPER
Governor
MICHAEL S. PEGAN
Secretary
S. DANIEL SMITH
Interim Director
Ms. Elizabeth Wike
NORTH CAROLINA
Environmental Quality
April 8, 2019
DAK Americas LLC - Cedar Creek Site
3216 Cedar Creek Road
Fayetteville, NC 28312
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000389
DAK Americas LLC - Cedar Creek Site
Cumberland County
Dear Ms. Wike:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please
review the draft carefully to ensure thorough understanding of the conditions and
requirements it contains.
The draft permit contains the following significant changes from the facility's current permit:
1. You are required to collect analytical and qualitative monitoring samples during
"measurable storm events" as defined in Part II, Section B. This term is
different from the "representative storm event" in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in
Part II, Section A.
3. Changes have been made to several monitoring parameters, including a change to
two benchmarks. Stormwater benchmarks are not permit limits, but rather
guidelines for implementing the Stormwater Pollution Prevention Plan (SPPP). A
benchmark exceedance is not a permit violation; however, the permittee must
respond to exceedances as directed in the Tiers.
Vehicle maintenance (Tables 5,6) monitoring parameters have been
revised as follows:
o Non -Polar Oil & Grease [EPA Method 1664 (SGT-HEM)]
replaces Oil & Grease/TPH. The benchmark for Non -polar Oil &
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Grease using this method is 15 mg/L. This requirement appears in
all individual stormwater permits; however, it only applies to
facilities that perform onsite vehicle maintenance activities. If the
facility begins vehicle maintenance during the permit cycle, the
requirements shall apply.
o pH monitoring is no longer required for discharges only associated
with vehicle maintenance activities.
4. Tiered responses have been added to this permit. Exceedances of benchmark
values require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater Best Management Practices
(BMPs) in a tiered program in accordance with Part II, Section B of this permit.
5. A new section on Special Conditions has been added in Part II, Section E to
comply with federal regulations requiring electronic submittal of discharge
monitoring reports.
6. Civil and administrative penalty amounts have been updated to reflect current
federal law in Part III, Section A, 2(b) and (g).
Please review the draft permit and submit any comments to me no later than 30 days following
your receipt of the draft. Comments may be emailed to me at [e-mail] or
mailed to my attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service
Center, Raleigh, NC 27699-1612. If you have any questions, please email me or call me at (919)
707-3648.
Sincerely,
Lauren Garcia
DEMLR Stormwater Division
Attachment: Draft Permit NCS000389
cc: Elizabeth Wike, DAK Americas LLC — Cedar Creek Site, [e-mail]
Mike Lawyer, DEMLR Fayetteville Regional Office, [e-mail]
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